1740 Broadway T: 212.468.4800 www.dglaw.com | ||||
New York, NY 10019 F: 212.468.4888 | ||||
Direct Dial: 212.468.4944 Personal Fax: 212.974.6969 Email: rnorton@dglaw.com |
January 19, 2018
Carlos Pacho
Senior Assistant Chief Accountant
AD Office 11 – Telecommunications
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Re: | WPP plc |
Form20-F for the Fiscal Year Ended December 31, 2016
Filed April 28, 2017
FileNo. 000-16350
Dear Mr. Pacho:
On behalf of WPP plc (the “Company”), this letter responds to the comment received from the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) in a letter dated November 20, 2017 (the “Comment Letter”) pertaining to the captioned report on Form20-F and the Company’s response letter dated November 14, 2017. For ease of reference in this letter, the Commission’s comment contained in the Comment Letter is reproduced inbold, and the response of the Company is shown below such comment. We note that the below question makes reference to the Company’s Consolidated Income Statement, pageF-8.
1. | We note your response to comment one. Please provide us with a schedule showing your proposed revised income statement presentation for the last two fiscal years. |
A schedule showing the proposed revised income statement presentation for the last two fiscal years is included below. Please note that this schedule is provisional and therefore subject to finalization following completion of the audit.
Carlos Pacho
Securities and Exchange Commission
January 19, 2018
Page 2
Consolidated income statement
For the years ended 31 December 2016, 2015
2016 £m | 2015 £m | |||||||
Revenue | 14,388.9 | 12,235.2 | ||||||
| ||||||||
Direct costs of services | (1,991.1 | ) | (1,710.9 | ) | ||||
| ||||||||
Revenue less direct costs of services | 12,397.8 | 10,524.3 | ||||||
| ||||||||
Other costs of services | (9,357.0 | ) | (7,998.3 | ) | ||||
| ||||||||
Gross profit | 3,040.8 | 2,526.0 | ||||||
| ||||||||
General and administrative costs | (977.7 | ) | (894.0 | ) | ||||
| ||||||||
Operating profit | 2,063.1 | 1,632.0 | ||||||
| ||||||||
Share of results of associates | 49.8 | 47.0 | ||||||
| ||||||||
Profit before interest and taxation | 2,112.9 | 1,679.0 | ||||||
| ||||||||
Finance income | 80.4 | 72.4 | ||||||
| ||||||||
Finance costs | (254.5 | ) | (224.1 | ) | ||||
| ||||||||
Revaluation of financial instruments | (48.3 | ) | (34.7 | ) | ||||
| ||||||||
Profit before taxation | 1,890.5 | 1,492.6 | ||||||
| ||||||||
Taxation | (388.9 | ) | (247.5 | ) | ||||
| ||||||||
Profit for the year | 1,501.6 | 1,245.1 | ||||||
| ||||||||
Attributable to: | ||||||||
| ||||||||
Equity holders of the parent | 1,400.1 | 1,160.2 | ||||||
| ||||||||
Non-controlling interests | 101.5 | 84.9 | ||||||
| ||||||||
1,501.6 | 1,245.1 | |||||||
| ||||||||
Earnings per share | ||||||||
| ||||||||
Basic earnings per ordinary share | 109.6p | 90.0p | ||||||
| ||||||||
Diluted earnings per ordinary share | 108.0p | 88.4p | ||||||
|
* * * *
On behalf of the Company we acknowledge that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
Please do not hesitate to contact the undersigned at (212)468-4944 if you have any further comments or questions.
Very truly yours,
/s/ Ralph W. Norton
Cc: | Andrea Harris, Esq. |